An email from Wisconsin DNR spokesman William Cosh to Mark Mohr (pg 2 of the document) in the Walker Administration from September 28, 2011 addresses media questions, concern about frac sand mining in West Central Wisconsin:
It’s one thing to measure particulate matter in ambient air, which the DNR does. It is quite another to determine what percentage of particles, of varying size, are composed of crystalline silica…there are no generally accepted methods for monitoring them and no federal or state standards to apply. Nor is there any compelling evidence from health studies to indicate an urgent need for such testing.
The unprecedented growth of sand mining in West Central Wisconsin over the past year has created a policy crisis for the state and the DNR. The above statement reveals the nature of this policy lapse. First, the lack of effective and accurate measurement, monitoring, and regulation of air quality. Second, the current DNR (and state) administration is ignoring potential future health impact of airborne crystalline silica.
Silica studies done by DNR scientists have been extensive – as the agency had anticipated the boom in sand mining over the past decade. The most extensive study (NR445) was to have been completed under Administrative Rule by July 1, 2006. It was finalized and submitted 5 years late – August 2011. The study specifically cites the shortcomings of current regulatory methods and standards:
A recurring theme from the literature review and survey is that very little conclusive information exists regarding sources, controls or levels of silica present in ambient air. This lack of data means it is not
currently possible to determine conclusively whether or to what extent the quantity, duration or types of silica emissions in the state may be a public health concern. It would take significant additional efforts to fill in these data gaps.
The health risks for crystalline silica under PM4 (the size in microns – millionths of a meter – of most risk to humans) were documented in the report:
The National Toxicology Program Eleventh Report on Carcinogens (2005) states that respirable crystalline silica is “known to be a human carcinogen, based on sufficient evidence of carcinogenicity from studies in humans, indicating a causal relationship between exposure to respirable crystalline silica and increased lung cancer rates in workers exposed to crystalline silica dust”. In addition, IARC notes that: “Crystalline silica inhaled in the form of quartz or cristobalite from occupational sources [i.e.,
workplace exposures] is carcinogenic to humans,” and is classified as a Group 1 carcinogen (IARC 1997).
The report cites other non-cancerous illnesses as well, including pulmonary, kidney, and silcotuberculosis. Contrary to Cosh’s email to the Walker Administration – there are numerous studies that document effective testing. The problem in our current situation – it is not in practice or widely accepted.
An independent citizens group – “Concerned Chippewa Citizens” conducted its own study monitoring air quality around an operating mine near Chippewa Falls. The study conducted by Jeff Falk (a trained statistician from Fountain City) raises serious questions about air quality and testing, and acknowledges its own shortcomings – yet the data is consistent and concerning. There are numerous occurrences within a 24 hour period that potentially exceed EPA standards.
Independent studies are being conducted by Dr. Crispin Pierce at UW-Eau Claire on air quality around the sand mines. Dr. Pierce’s study took baseline samples prior to mine operation, and subsequently conducted sample taking after the mine became operational. The study took a “snapshot” of an 8-12 hour period; and according to Dr. Pierce, there was a noted increase in aerosol (particle and airborne) levels. While the study has not yet identified the nature of the “aerosol” particulate – something caused an increase. Dr. Pierce and his colleagues are continuing identification and sampling in the area of the mines.
The DNR is virtually ignoring these independent studies, citing a “flawed” gathering mechanism. The DNR points to the standard it enforces as being sufficient for the current operations. There are several problems with these “standards.” There are exemptions which (under the current “job creation” and customer service mission of state agencies) are relatively loose compared to health consequences. Also, by DNR admission, the air monitoring science and evaluation is insufficient.
Sampling (where applicable) only needs to take place every 6 days at PM10 – in which case you “oversample,” capturing a high amount of irrelevant material. Or PM 2.5 in which case you “undersample”, much of the critical PM 4 particulate escaping. This is important – the ideal sample standard is PM 4. The gathering method and standard for this does not exist. As one DNR official admitted, the mining development moved faster than regulation.
Taking into account the consequences, lack of accurate measurement surrounding air quality and sand mining, and the known health risks involved, the DNR and state should immediately issue a moratorium on sand mining development.
The final issue being completely ignored by the state agency charged with protecting natural resources is this – the sand country of Aldo Leopold is being ravaged, with little to no state regulation of protection of this unique environment. In fact, it is the unique-in-all-the-world that makes this land so valuable, even to the mining companies.
The legacy of this Administration and DNR is being carved out of the sand and earth. It will be years before we know the health and environmental costs. Weighed against how long the jobs will last, and what (if any) other revenue benefit to the region there is – one must ask – is it worth it?
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